THE UNITED STATES PHARMACOPOEIA

The United States Pharmacopoeia is a book prepared by a national organization chosen by the medical and pharmaceutical colleges and societies of the country. This organization meets once in each ten years. The principal object of these decennial conventions is to appoint a committee for revising the United States Pharmacopoeia. At the Convention which assembled in Washington in 1910, much to my surprise, I was elected president of the Convention for the decennial period ending in 1920. Ex officio I became a member of the committee on revision. The food-law specifically recognizes the United States Pharmacopoeia, both as to the standard of quality of the remedies described therein and the methods of analysis by which the purity of remedies is established. Its activities, therefore, are specifically prescribed by the Congress of the United States as one of the methods of administering the Food and Drugs Act. Essential oils are frequently standardized and prescribed in the Pharmacopoeia. I was allowed to select the particular part of the revision work over which I was chosen to preside. I had for several years, on account of essential oils being agricultural products, collected and studied large numbers of these bodies. This work was assigned to the committee studying essential oils. I was very much surprised, therefore, to receive from the Secretary of Agriculture a written statement for the amount of time consumed in these investigations and the probable expense to date of the work done. Any one who is interested in the further details of this remarkable request will find them recorded on page 808 and following of the proceedings of the Moss Committee.

The methods of analysis and the standards of purity of drugs prescribed by the Pharmacopoeia are specifieally adopted by the Food and Drugs Act. The regulations enacted for the enforcement of the Food and Drugs Act are as follows:

Unless otherwise directed by the Secretary of Agrieulture, the methods of analysis employed shall be those employed by the Amociation of Official Agricultural Chemists and the United States Pharmacopoeia.

I made the following statement to the committee:

I may say, Mr. Chairman, that never in the history of the Pharmacopoeia has such pains been taken to make it as perfect as possible. In view of the fact that Congress has made it the official standard of drugs and medicines, the present committee is taking special pains to get all the information possible to make the new edition as useful as possible, for the purpose of securing purity of drugs in this country.

During my absence from the city I was informed by the Secretary of Agriculture on June 15 that Dr. Dunlap had told him he had information that work was going on in the Bureau of Chemistry in the revision of the Pharmacopoeia.

When Dr. Dunlap appeared as a witness before the committee he was asked: "What are your duties as associate chemist?"

He replied: "I have none."

Evidently he was mistaken. It was he who by his detective abilities discovered that the Chief of the Bureau of Chemistry had deceived the Secretary of Agriculture and induced him to appoint Dr. Rusby illegally. Continuing the exercise of these Sherlock Holmes activities he discovered the Bureau of Chemistry was doing illegal work in examining the agricultural products known as essential oils. These were noble and important functions that somebody had to perform. It was a great stroke of good luck that put Dr. Dunlap into the Department for this worthy purpose. President Roosevelt deserves the gratitude of the future for discovering and having appointed a scientist of such ethical activities and achievements. As a result of Dr. Dunlap's activities the Solicitor had told the Secretary that these activities of the Chief of the Bureau were clear violations of law and the Secretary instructed me to do no more work of any kind in connection with revision of the Pharmacopoeia. At this same time the members of the Referee Board were paid salaries exactly as Dr. Rusby was and had spent already several hundred thousand dollars in their attempts to prevent the food law from being enforced. I found that the total expense which had been incurred by the Bureau of Chemistry up to the time the order was issued to "cease and desist" from these activities as violations of law was exactly $55. Of all the tremendous inconsistencies in regard to illegal expenditures in the Bureau of Chemistry in connection with the Remsen Board, there was nothing so clearly and distinctly disclosed as the complete propriety of the activities of the Bureau of Chemistry in securing a proper revision of the Pharmacopoeia. This order forbidding work in the Bureau of Chemistry along that line was still in force in 1912 when I retired from the Bureau. I do not think it was removed during the remainder of my decennial term.

This pusillanimous persecution of itself amounts to nothing. It illustrates the petty meanness of the environment which the Chief of the Bureau was forced to endure for so many years. The report of the Moss Committee disclosed the whole fabric of the net in which the enemies of the food law had planned to enmesh those charged by law to enforce it. In regard to this matter the following quotation from the Moss Committee's record' is illuminating:

(MOSS COMMITTEE)

Page 887-888.

THE CHAIRMAN: Did I understand you correctly in your testimony, when I was asking questions, to say you can extend the functions of the Bureau of Chemistry, provided it is not prohibited by law?

SECRETARY WILSON: I can use administrative discretion that is not prohibited by law. * * * I can illustrate that by what happened at Denver. Dr. Long is a member of the Referee Board from Chicago. There had been going through the papers and being stated by the chemists, and so forth, that the best use to which we could put benzoate of soda, and the use to which it generally was put, was to preserve decaying vegetables and fruits. Dr. Long had made some extensive investigations and reported there that benzoate of soda would not preserve either vegetables or fruits.

THE CHAIRMAN: Did I understand you to say, in answer to Mr. Sloan, that there was no authority in law for this pharmacopoeia work--that it was absolutely forbidden by law to do this work?

SECRETARY WILSON: No authority.

THE CHAIRMAN: Coming back to your idea that you can extend the functions of the Bureau of Chemistry, providing it is not forbidden by law, would you not have authority, under your construction, to permit Dr. Wiley to do this work if you had cared to do so?

SECRETARY WILSON: No; administrative discretion can only be used in furtherance of the object of the law.

Page 894-895.

MR. HIGGINS: Have you pursued, Mr. Secretary, any different policy toward the Chief of the Bureau of Chemistry than with reference to any other chief in your department?

SECRETARY WILSON: Not a particle. You could not understand, if you happened to look over the transom of the door and see Dr. Wiley and me discussing one of his new farms

MR. HIGGINS (interposing): He is also an agriculturist?

SECRETARY WILSON: He has farms, but he and I discuss them. I give him advice. I am no chemist; but, then, he is no farmer (laughter), and so we swap information, you know. There is one delightful thing about the Doctor: he has humor, and unless I once in awhile get a laugh I would run back to Iowa and stay there. The Doctor has pleasant humor, and he is a pleasant companion. If you saw us in one of these interviews you would not believe there ever was any trouble about benzoate of soda.

MR. HIGGINS: You discuss pleasant subjects at those interviews?

SECRETARY WILSON: Always.

MR. SLOAN: You are both bonnie Scots, are you not?

SECRETARY WILSON: I am direct, but I imagine he is tainted with the blood.

The Bureau of Chemistry was not treated like other Bureaus. Secretary Wilson was well aware of that fact. In no other Bureau did he appoint an Associate Chief, as he did in the Bureau of Chemistry, without ever consulting the Chief of that Bureau. In no other bureau were funds specifically appropriated for definite purposes used without the consent of the chief for diametrically opposite purposes. In no other Bureau were changes made in administration without consulting the Chief of the Bureaus involved. No other Chief of Bureau was ever secretly tried before the personnel board, found guilty, and sentenced to be dismissed from the service, as was the Chief of the Bureau of Chemistry. In no other Bureau were important component parts thereof separated and put into an independent bureau as was the case in the Bureau of Chemistry with Soils and Investigations of Road Building Materials. While it is true that the Secretary and the Chief of the Bureau were on friendly terms personally, the Secretary never took the advice of the Chief of the Bureau of Chemistry on the important matters above mentioned. In no other bureau were funds appropriated for a specific purpose used for paying employees who were ordered to report to the Solicitor of the Department. These are only a few of the illustrations of the different treatment accorded to the Bureau of Chemistry.